Privacy Policy

SPARQLEY NETWORK LIMITED, along with its affiliates and subsidiaries (collectively referred to as “SPARQLEY NETWORK LIMITED” or “we”), is committed to protecting your privacy. This Privacy Policy (“Policy”) outlines our online data protection practices, detailing the types of information we collect when you visit our websites at sparqleynetwork.com and its subdomains (“Websites”). It also explains how we use your information, your rights concerning your personal data, and how to contact us for further inquiries.

By accessing our Websites, submitting inquiries, or applying for job positions, you consent to the collection and use of your information as outlined in this Policy. Please review this Policy carefully before using our Websites. Our Websites are not intended for individuals under 16 years old, and we do not knowingly collect personal data from children in this age group.

This Policy is an integral part of our Terms of Use and may be updated periodically. We encourage you to review it regularly.

For anyquestions regarding this Policy, please contact us at legal@sparqleynetwork.com.

Under the EU General Data Protection Regulation (“GDPR”), SPARQLEY NETWORK LIMITED acts as both a data controller and processor, determining how personal data is collected and used. We ensure compliance with all relevant data protection laws and safeguard the personal data provided to us.

If you apply for a job through our Website, your personal information is processed by both SPARQLEY NETWORK LIMITED and our third-party recruitment service provider, Workable. In such cases, SPARQLEY NETWORK LIMITED remains the data controller, while Workable acts as the processor. We take appropriate measures to ensure third-party service providers handle your data securely and in accordance with this Policy.

3.1 Information You Provide

• When contacting us via email or contact forms, we collect your name, phone number, email address, and message content.

• When applying for a job, we may collect your name, email, phone number, location, and any information in your CV or accompanying documents.

• If referred by another person or found via job boards, we may collect relevant employment details.

• If you represent a client, partner, or vendor, we may collect business contact details, job title, and organization-related information.

3.2 Information Collected Automatically

• Device details (hardware model, OS version)

• Website usage data (IP address, location, browser type, navigation paths)

• Cookies and tracking technologies for analytics and advertising (see Section 7 for details)

• Log files to monitor and improve our Website’s security and functionality

4.1 Communications (Legitimate Interest, GDPR Art. 6(1)(f))

• Responding to inquiries

• Scheduling meetings and calls

• Storing communication records

• Providing customer support and responding to service requests

4.2 Marketing & Analytics (Consent, GDPR Art. 6(1)(a))

• Conducting market research

• Analyzing visitor interactions

• Sending promotional materials (if subscribed)

• Customizing user experience based on preferences

• Conducting performance analysis of advertising campaigns

4.3 Recruitment

• Processing applications and considering candidates (Consent, GDPR Art. 6(1)(a))

• Sharing CVs with clients upon request (Legitimate Interest, GDPR Art. 6(1)(f))

• Conducting background checks when required by clients

• Assessing candidates for both current and future job opportunities

• Managing candidate databases for recruitment efficiency

• Facilitating visa or relocation processes when applicable

4.4 Business Operations (Legitimate Interest, GDPR Art. 6(1)(f))

• Managing business relationships with clients, vendors, and partners

• Organizing contracts and compliance obligations

• Screening for anti-corruption and fraud prevention

• Ensuring adherence to industry standards and regulatory compliance

• Facilitating internal audits and business performance evaluations

• Conducting financial and operational reporting

4.5 Corporate & Investor Relations (Legal Obligation, GDPR Art. 6(1)(c))

• Organizing corporate events

• Fulfilling disclosure and reporting requirements

• Managing bank accounts and legal compliance

• Supporting investor relations and financial transparency

• Providing required documentation for regulatory inspections

• Ensuring compliance with anti-money laundering regulations

4.6 Security (Legitimate Interest, GDPR Art. 6(1)(f))

• Securing the Website

• Preventing fraud and ensuring compliance

• Monitoring office visitors for security purposes

• Implementing cybersecurity measures to prevent data breaches

• Conducting risk assessments to enhance organizational security

• Monitoring access to IT systems and data protection infrastructures

We process personal data through:

• Collection, storage, and retrieval

• Structuring and organization

• Secure deletion when no longer necessary

We may share your data within SPARQLEY NETWORK LIMITED's global entities, as well as with auditors, regulatory authorities, service providers, and clients on a need-to-know basis.

As a data subject, you have the right to:

• Access, correct, or delete your personal data

• Object to processing or automated decision-making

• Restrict or request the transfer of your data

• Withdraw consent at any time

To exercise these rights, please contact legal@sparqleynetwork.com We may verify your identity before fulfilling requests. Response time is one month.

We implement technical and organizational measures to protect personal data. Your data is stored on secure servers, including those of trusted cloud service providers. Security measures include encryption, access controls, and routine audits to safeguard information against unauthorized access, alteration, or disclosure.

We retain personal data only as long as necessary for processing purposes or as required by law. The retention period varies depending on the nature of the data:

• Contact information: Retained for the duration of active communication and for a reasonable period afterward.

• Recruitment data: Retained for up to 3 years after the last interaction unless legally required to keep it longer.

• Business-related data: Retained for contract execution and compliance with financial reporting regulations.

• Security logs: Retained for 3 years for fraud prevention and security monitoring.

Once no longer needed, data is securely deleted. Data may be retained longer for legal proceedings, fraud prevention, or compliance obligations.

By using our Website, you acknowledge the collection and use of your data in accordance with this Policy. For further information, contact us at legal@sparqleynetwork.com.